The debate over the 1,500-hour pilot rule needs Quantitative Analysis not Subjective Judgment

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1,500 Hour Pilot Rule

Quantitative Analysis Providing Hard Data

Some airlines aver that the higher minimum hour requirement is precluding them from finding qualified pilots. The proponents of the new criteria believe the more rigorous rule is needed for safety, to avoid the tragedies of the past. A recent Forbes article asserts that the regulation is not needed. History suggests that the roots of this requirement are not founded in analytical research, but the opponent’s argument is no more quantitative in his assertion.

More is needed to resolve this debate.

Congress in the AIRLINE SAFETY AND FEDERAL AVIATION ADMINISTRATION EXTENSION ACT OF 2010 in response to the tragic Continental 3407 Crash and the work of Families of Continental Flight 3407 coalition. The mandates of that legislation are extensive:

  • Sections 202 -215 require periodic reports to Congress, a new database on pilots, hiring any pilots, initiating of task forces, commissioning of IG reports, convening of an ARC, a study of best practices, an NPRM on training, random inspections of regional air carriers annually, adoption of SMS and FOQA.
  • Section 216: Requires FAA Administrator to conduct a rulemaking that changes screening and qualification requirements for all Part 121 pilots, requiring ATP license/appropriate multi-engine experience. Includes default provision that ATP requirement is mandatory within 3 years.
  • Section 217: Requires FAA Administrator to conduct a rulemaking that modifies the requirements to earn an Airline Transport Pilot (ATP) license. Focuses on Flight Hours (including in difficult operational conditions) and additional qualitative elements.

In response to the accident and the Act, the FAA initiated an Aviation Rulemaking Committee on the subject, sent Congress a report in 2011 and issued an NPRM. In the FAA’s issuance of final rule and its preamble (2013), the history of the new PIC and SIC requirements was reviewed:

“In developing this final rule, the FAA reviewed the requirements set forth in the Act, reconsidered the FOQ ARC recommendations, conducted a new accident analysis, 7 reviewed NTSB Safety Recommendations, and considered the public comments to the NPRM. The provisions of this final rule are consistent with the statutory mandates set forth in the Act.”

Later in the same Federal Register notice, it was stated:

Section 217 also directs that the minimum total flight hours to be qualified for an ATP certificate shall be at least 1,500 flight hours.”

NEITHER THE FAA ANALYSIS OF THE NTSB RECORDS NOR THE REVIEW OF THE ARC CITED ANY FORMAL CORRELATION BETWEEN THE SELECTION OF THE 1,500-HOUR STANDARD AND REDUCTION OF THE RISK.

The Families of Continental 3407

The Families of Continental 3407, Senators Gillibrand and Schumer plus Western New York’s four House members (two Democrats, two Republicans) have vowed to do everything to defeat any effort to weaken their safety standard.

Regulations Should Help Americans. This One Doesn’t.

Forbes magazine has published this provocative article by Dr. Nunes which concludes that the increase in required pilot hours does not help; his words are as follows:

The 1500-hour rule doesn’t improve air safety. What it does is dramatically increase pilot training costs – estimated to be in the tens of thousands of dollars – as new recruits scramble to rack up extra flying time. More importantly, the rule reduces the number of pilots eligible for recruitment by American carriers. The result? Republic Airways, which operates regional flights for American, Delta and United Airlines, sought protection from its creditors last year after experiencing pilot shortages. Other carriers have reported service cuts for the same reason

dr ashley nunesDr. Ashley Nunes is an analyst and consultant specializing in regulatory policy, human factors and workforce productivity. With over a decade of academic and industry experience, he has lectured globally on the challenges facing developed economies and has led research projects sponsored by the Department of Defense and the Federal Aviation Administration.

Dr. Nunes holds academic appointments at the Massachusetts Institute of Technology and L’Universite Paris Descartes. He earned his Ph.D. in Engineering Psychology from the University of Illinois at Urbana Champaign (USA), where his research examined the scientific merit of raising air traffic controller retirement ages.

Dr. Nunes is a contributor to Forbes and The Hill and has previously written for Aviation Week, The American Scientist, National Public Radio, Politico Europe, Wired, and the Scientific American among others. His work has been featured by the BBC, ABC News, and the Globe and Mail.

His current areas of interest include fatigue risk management, workforce productivity assessment and the economic analysis of human performance.

The author frequently voices his opinion about aviation safety and his episodic analysis is interesting, but not determinative. In fact, the Doctor’s proof is contained in these paragraphs:

The pilots of Singapore Airlines 006 that crashed in Taiwan each had more than 1500 hours on the job. So did the pilots of Air France 447 that crashed off the Brazilian coast. So did the crew of KLM 4805 which was involved in aviation’s worst accident. Eastern Airlines 401, Air Florida 90, American Airlines 587, the list of crashes that have involved experienced professionals is endless.

These anecdotes are backed up by hard data. One government study found only 7 of the 31 accidents reviewed to involve pilots with fewer than 1,500 hours on the job. Another that the best performing pilots weren’t always the ones who had flown the most.

Anders Ericsson isn’t surprised. The Florida State University professor has spent three decades studying what it takes to be an expert. Ericsson’s work shows that skills and abilities only get better when they are, “deliberately practiced.” In other words, quality of time on the job is what counts, not quantity. That sentiment is as true for pilots as it is for violinists, stockbrokers and spelling bee contestants.

The National Transportation Safety Board (NTSB) agrees. Before the 1500-hour rule went into effect, the NTSB stated, “total flight hours . . . does not necessarily equate to the level of knowledge, skills and professionalism required for consistently safe flight operations.” Similar views were held by the FAA. But the agency ultimately caved under pressure from lawmakers and special interest groups.

EVEN THE NUMBERS CITED IN THE NTSB QUOTE ARE ANECDOTAL IN NATURE. DR. NUNES’ EXPERT OPINION IS NOT OF GREATER ANALYTICAL VALUE THAT THE SUPPORT FOR THE 2010 MANDATE.

Greater evidence, hard correlation between levels of experience and pilot error, is needed to allow the FAA to reconsider the Congressionally mandated hour rule. The FAA has built an extensive data base on all aspects of safety. NASA maintains a very useful repository of anonymous reports of flying errors, the Aviation Safety Reporting System, which should be a fertile field for quantitative research. Within the SMS data collection…

faa asias asrs

…the FAA has established an incredibly extensive resource called the Aviation Safety Information Analysis and Sharing (ASIAS) system. Included in that memory should be all of the records which required to perform a sophisticated statistical analysis to define the optimal experience level for the cockpit – individually and collectively.

A deep investigation of actual operational experience (remember: for many years pilots flew with less than the now statutorily prescribed minimum) might provide hard data on questions like:

  1. Are there more precise criteria than just hours (for example military engine life is measured in thrust excursion cycles; might experience as an SIC successful dealing with some problem be a strong predictor that she/he might be well qualifies as a PIC?)
  1. Are younger pilots who have less hours in the cockpit more attentive?
  1. Does that greater attentiveness offset the lack of experience?
  1. Does greater experience equate to better stick and rudder skills, thus resulting in better ability to respond to an unexpected problem?
  1. Or do cockpit skills degrade over time?
  1. The modern cockpit requires greater competence in data input and systems awareness; doe those skills positively correlate with age/experience along a spectrum of those two criteria?
  1. Is there a SET of skills which the PIC must have?
  1. Is there a distinct SET of skills which the SIC must have?
  1. Or is there a collective set of skills which the PIC and SIC must have between them?
  1. Are there ways in which to identify which pilots have which skills?
  1. Does the determination of such skills last in definitively or must they be reassessed periodically?
  1. ETC.

Dr. Nunes could create powerful support for the conclusion he articulated (or if the facts support the 1,500 hour or other rule—assistance for aviation safety) by using his Ph.D. in Engineering Psychology to answer these open issues. Such an inquiry {perhaps relying on the research by the works of Drs, Kahneman and Tversky, as described in The Undoing Project} to provide the dispositive quantitative answers to the twelve questions (and more?) asked above. Without such indisputable proof, the debate over the 1,500 hour criteria will continue on a subjective level. His conclusions, if based on real data, may allow the reconsideration of the 1,500-hour rule or some more precise response to this complicated problem. If nothing else, Dr. Nunes might provide useful evidence for the on-going Pilot Professional Development NPRM.

THAT WOULD BE A GREAT BENEFIT TO ALL INVOLVED IN THIS EMOTIONALLY AND ECONOMICALLY CHARGED DEBATE AND POSSIBLE A GREAT ADVANCE IN AVIATION SAFETY.


 

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